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When Is the Digital Product Passport Mandatory? The Full Deadline Matrix

One master table of every EU Digital Product Passport date - which regulation, which industry, entry into force, application, and first mandatory passports. Binding dates are marked confirmed; delegated-act dates are marked indicative. Every date is cited to an authoritative source and stamped last verified July 2026.

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The Digital Product Passport is not one deadline - it is a matrix of regulation-by-industry dates, and only two are legally fixed today. The battery passport is binding from 18 February 2027 under the EU Batteries Regulation (EU) 2023/1542, Article 77. The ESPR registry and customs framework applies from 19 July 2026 under Regulation (EU) 2024/1781. The Toy Safety Regulation (EU) 2025/2509 makes a DPP mandatory for toys, applying from 1 August 2030. Every other product group - textiles, iron and steel, aluminium, tyres, furniture, mattresses, electronics - depends on an ESPR delegated act that has not yet been published, so its date is indicative, not binding, and can move. This page is the honest master matrix: it separates the confirmed dates from the indicative windows, cites each one to EUR-Lex or the European Commission, and links to a per-industry deadline page for the field-level detail. Where a date is not yet fixed, we say so plainly - because in compliance a confidently wrong date is worse than an honest unknown.

  • 18 July 2024Done

    ESPR enters into force (confirmed)

    Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation, applies from 18 July 2024 and is the horizontal legal basis for the DPP. It fixes no product-group deadline itself; those arrive with each delegated act. Source: EUR-Lex 32024R1781.

  • 16 April 2025Done

    First ESPR working plan adopted (confirmed)

    The Commission adopted the 2025-2030 working plan naming the first priority groups: iron and steel, aluminium, textiles (apparel), tyres, furniture, mattresses. The dates it gives are indicative, not legal deadlines. Source: European Commission working plan announcement, 16 April 2025.

  • 19 July 2026Upcoming

    ESPR registry + customs framework applies (confirmed)

    The ESPR registry and customs verification framework apply from 19 July 2026 under Regulation (EU) 2024/1781. This is a confirmed framework date, not a product-passport deadline. Source: EUR-Lex 32024R1781.

  • ~2026 (indicative)Upcoming

    Iron and steel delegated act expected

    Iron and steel is the earliest priority group, with a delegated act indicatively targeted around 2026 and a compliance date typically 18-36 months later (~2028). Indicative, not binding, until the act is published. Source: ESPR working plan.

  • 18 February 2027Next deadline

    Battery passport mandatory (confirmed, binding)

    Under Article 77 of the Batteries Regulation (EU) 2023/1542, the battery passport is mandatory from 18 February 2027 for EV batteries, LMT batteries and industrial batteries above 2 kWh placed on the EU market. A hard, binding deadline. Source: EUR-Lex 32023R1542.

  • ~2027 (indicative)Upcoming

    Textiles, aluminium and tyres delegated acts expected

    Textiles (apparel), aluminium and tyres are indicatively scheduled for delegated acts around 2027, with compliance typically ~2028-2029. Each becomes binding only when its act is published. Source: ESPR working plan.

  • ~2028 (indicative)Upcoming

    Furniture delegated act expected; ESPR mid-term review

    Furniture is indicatively scheduled around 2028; a mid-term review of the working plan is also due around 2028. Indicative. Source: ESPR working plan.

  • ~2029 (indicative)Upcoming

    Mattresses delegated act expected

    Mattresses round out the first priority groups, indicatively around 2029. Indicative. Source: ESPR working plan.

  • 1 August 2030Upcoming

    Toy DPP mandatory (confirmed)

    The Toy Safety Regulation (EU) 2025/2509 (in force 1 January 2026) makes a DPP mandatory for all toys placed on the EU market from 1 August 2030, after a 54-month transition. Source: European Commission, toy safety rules.

How to read it

Confirmed dates versus indicative windows.

  • CONFIRMED - Battery passport
    18 February 2027, Regulation (EU) 2023/1542 Article 77 - EV, LMT and >2 kWh industrial batteries. Binding.
  • CONFIRMED - ESPR registry + customs
    19 July 2026, Regulation (EU) 2024/1781 - horizontal framework date, not a passport deadline. Binding.
  • CONFIRMED - Toys
    DPP mandatory 1 August 2030, Regulation (EU) 2025/2509 (in force 1 January 2026). Binding.
  • INDICATIVE - Iron and steel
    delegated act ~2026, compliance ~2028 - not binding until the act is published.
  • INDICATIVE - Textiles (apparel) and footwear
    delegated act ~2027, compliance ~2028-2029 - not binding until published.
  • INDICATIVE - Aluminium
    delegated act ~2027 - not binding until published.
  • INDICATIVE - Tyres
    delegated act ~2027 - not binding until published (builds on the existing EU tyre label).
  • INDICATIVE - Furniture
    delegated act ~2028 - not binding until published.
  • INDICATIVE - Mattresses
    delegated act ~2029 - not binding until published.
  • NO FIXED DATE - Electronics
    covered by ESPR horizontal repairability and recyclability measures and future delegated acts; no single DPP date is fixed yet.
  • NO FIXED DATE - Cosmetics
    not a priority product group in the 2025-2030 ESPR working plan; no DPP obligation or date is fixed. Treat any specific cosmetics DPP date you see elsewhere with caution.
  • Packaging
    driven by the Packaging and Packaging Waste Regulation (EU) 2025/40, a separate regime from ESPR, with its own phased dates rather than one DPP date.

Read the matrix by legal certainty, not by industry alphabet. Two engines drive it. The Batteries Regulation (EU) 2023/1542 gives the one hard consumer-facing deadline: 18 February 2027 for the battery passport. ESPR (EU) 2024/1781 is a framework whose product deadlines land only when each delegated act is published - the 16 April 2025 working plan gives indicative timings (iron and steel ~2026, textiles, aluminium and tyres ~2027, furniture ~2028, mattresses ~2029), but these are expectations, not law, and shift with each preparatory study and consultation. The ESPR registry and customs framework itself applies from 19 July 2026, a confirmed framework date that is often misreported as a passport deadline - it is not one. Toys sit on their own regulation, (EU) 2025/2509, with a confirmed DPP application date of 1 August 2030. Packaging sits on the Packaging and Packaging Waste Regulation (EU) 2025/40, again separate from ESPR. Two groups people frequently ask about have NO fixed DPP date: electronics (covered by ESPR horizontal measures and a future delegated act) and cosmetics (not even in the working plan). Naming that honestly is the point of this page.

Per-industry deadlines

When is the DPP mandatory for your industry?

The matrix in summary. Each industry has a dedicated page with the honest current answer, the required data, a preparation timeline and how we automate it.

DPP Automate turns a moving matrix of deadlines into a repeatable release cadence. Because every passport rests on the shared ESPR Annex III spine - a unique product identifier, a GS1 Digital Link data carrier, and layered public and restricted access - a new industry deadline is a schema profile, not a new system. Our platform generates a compliant passport from a single product photo, and its REST API and MCP server let you import an existing catalogue in bulk (the `import_passports` tool) rather than hand-typing JSON per product. The AI does the field mapping from your source data to the active sector schema; Review mode keeps a human approving each draft, Auto mode publishes immediately. Every field is versioned with provenance back to its source, each passport is signed for independent verification, and records export JSON-LD ready for the European DPP registry. When a delegated act finally fixes a date we had listed as indicative, you absorb it as a schema update, not a fire drill - which is exactly why an honest, current deadline matrix and an automation platform belong on the same page.

Planning traps

The mistakes a wrong date causes.

Trap

Treating one date as the DPP deadline

Why it hurts

Reading a single headline date - often the 19 July 2026 registry date or the 2027 battery date - as the deadline for your product leads to either over-investing before your sector has an act, or missing a hard date you did not realise applied to you.

What to do instead

Use this matrix: separate the two confirmed binding passport dates (battery 18 Feb 2027, toys 1 Aug 2030) from the indicative ESPR windows and the 19 Jul 2026 framework date, and track your own product group specifically.

Trap

Trusting an unsourced indicative date as fixed

Why it hurts

Third-party blogs routinely present indicative delegated-act years (or invented cosmetics dates) as firm law. Budgeting or promising a board a fixed compliance date that later moves destroys credibility and can misallocate spend.

What to do instead

Only treat a date as binding if it traces to EUR-Lex or an official Commission act. Everything else is a planning window - build against the shared ESPR spine now so a shift costs nothing.

Trap

Waiting for your indicative date before starting

Why it hurts

The data work behind a passport - structuring composition, verifying recycled content, collecting supplier and lab evidence - takes longer than the transition period after an act is published. Waiting guarantees a scramble.

What to do instead

Start now on the common spine using published draft fields and automate the ingestion, so the day your act lands you are mapping data, not building a system from zero.

Re-verification

What to re-check, and when.

  • Confirmed-binding today (verify against your own catalogue): battery passport 18 February 2027; toy DPP 1 August 2030; ESPR registry/customs framework 19 July 2026.
  • Indicative (delegated act pending, can move): iron and steel ~2026; textiles, aluminium, tyres ~2027; furniture ~2028; mattresses ~2029.
  • No fixed date: electronics (ESPR horizontal + future act) and cosmetics (not in the 2025-2030 working plan) - do not plan to a specific DPP date for these yet.
  • Re-verify battery and toy dates each quarter against EUR-Lex; re-verify every indicative ESPR date when the relevant delegated act draft is published.
  • Re-check the 19 July 2026 registry date after it passes (copy flips to past tense) and re-check the working-plan indicative years after the ~2028 mid-term review.
Worked examples

Reading the matrix for real product lines.

Product line

EV + industrial battery maker

The question

Needs the one date that is legally certain and applies to it now.

The honest answer

Battery passport is binding on 18 February 2027 under Reg (EU) 2023/1542 Art 77 - confirmed, not indicative.

What to do

Plan to a fixed date; see the battery deadline page for the exact fields and start importing the catalogue now.

Product line

Apparel brand asking about textiles

The question

Wants a firm textile DPP date to budget against.

The honest answer

There is none yet - the textile delegated act is indicatively ~2027 with compliance ~2028-2029, but it is not law until published.

What to do

Treat it as a planning window, build on the shared spine now, and watch EUR-Lex for the act; see the textiles deadline page.

Product line

Cosmetics manufacturer

The question

Read online that a cosmetics DPP is due around 2026 and wants to confirm.

The honest answer

Cosmetics is not a priority product group in the 2025-2030 ESPR working plan; no DPP obligation or date is fixed. The 2026 figure is unsourced.

What to do

Do not plan to a cosmetics DPP date yet; see the honest cosmetics page and monitor the next working-plan review.

Deadline FAQ

When is the DPP
mandatory?

The questions people actually type into search, answered honestly - including where the date is not yet fixed.

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When is the Digital Product Passport mandatory?+

It depends on the product. Two dates are legally binding today: the battery passport from 18 February 2027 (Reg (EU) 2023/1542) and the toy DPP from 1 August 2030 (Reg (EU) 2025/2509). Most other groups - textiles, steel, aluminium, tyres, furniture - depend on an ESPR delegated act not yet published, so their dates are indicative (~2026-2029). Electronics and cosmetics have no fixed DPP date.

Is there a single DPP deadline for all products?+

No. The DPP is a matrix of regulation-by-industry dates, not one deadline. The ESPR framework applies from 19 July 2026 (registry and customs), but that is not a product-passport date. Each product group becomes mandatory on its own regulation or delegated act.

What does the 19 July 2026 ESPR date actually mean?+

It is the date the ESPR registry and customs verification framework applies under Regulation (EU) 2024/1781. It is a confirmed framework milestone, not the date any specific product needs a passport. It is often misreported as a general DPP deadline - it is not.

Is the battery passport date confirmed?+

Yes. 18 February 2027 is fixed by Article 77 of the Batteries Regulation (EU) 2023/1542 for EV, LMT and industrial (>2 kWh) batteries placed on the EU market. It is binding, not indicative, and does not depend on a delegated act.

Are the ESPR textile, steel and furniture dates final?+

No. They are indicative timings from the 2025-2030 working plan (steel ~2026, textiles/aluminium/tyres ~2027, furniture ~2028, mattresses ~2029). Each becomes binding only when its delegated act is adopted and its transition period ends. Treat them as planning windows.

Is a DPP required for cosmetics or electronics?+

Not on a fixed date. Cosmetics is not a priority group in the 2025-2030 ESPR working plan, so no DPP obligation or date is set. Electronics is covered by ESPR horizontal repairability and recyclability measures and a future delegated act, but no single DPP date is fixed yet.

When must toys have a Digital Product Passport?+

From 1 August 2030. The Toy Safety Regulation (EU) 2025/2509 entered into force on 1 January 2026 and makes a DPP mandatory for all toys placed on the EU market after a 54-month transition ending 1 August 2030.

How often is this deadline matrix verified?+

It was last verified in July 2026 against EUR-Lex and European Commission sources. We re-verify the confirmed dates each quarter and every indicative date whenever the relevant delegated-act draft is published, and update the stamp accordingly.

Know your date. Then automate the passport.

Whether your deadline is binding (batteries, toys) or still indicative (textiles, steel, furniture), the winning move is the same: build on the shared ESPR spine now and let the API and AI do the passport work. Run the free readiness check for your product group, or book a roadmap session and we will map your lines to the real matrix.

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